Paycheck Protection Program and Other Deadline Updates 4.13.20

The Biden Administration Corporate Tax Proposal

Non-Filers: Enter Payment Info Here

https://www.irs.gov/coronavirus/non-filers-enter-payment-info-here

Economic Impact Payments

https://www.irs.gov/coronavirus/economic-impact-payments

Deloitte Update on Phase 4 Covid-19 bill:
https://newsletters.usdbriefs.com/2020/Tax/ALS/200413_1.html?elqTrackId=22d5d793306e4f02950504730022a362&elq=79d172a9e23e48ccaae51a8e4d3f2c26&elqaid=69713&elqat=1&elqCampaignId=13291

/Ron Cohen, CPA, MST
Posted in
Classification of Accepted Patterns of Reorganization

Details of Patterns of Reorganization

Details of Patterns of Reorganization • “A” Reorganization • “B” Reorganization • “C” Reorganization • “D” Reorganization • “E” Reorganization • “F” Reorganization • “G” Reorganization “A” Reorganization Type “A” Reorganization consists of • Merger • Consolidation Both involve the acquisition of one company’s assets by another. Merger Explanation: • Target transfers its assets and…

Classification of Accepted Patterns of Reorganization

“B” Reorganization

“B” Reorganization Type “B” involves the acquisition of stock of one corporation by another, and the target corporation becomes a subsidiary of the acquiring, as a result. Requirements of “B” Reorganization 1) The acquisition must be one of a series of acquisitions that are part of an overall plan to acquire the requisite control. 2)…

Classification of Accepted Patterns of Reorganization

“C” Reorganization

“C” Reorganization The target corporation must liquidate as part of the plan of reorganization unless the IRS waives this requirement.’ As a result, the shareholders of the target corporation become shareholders in the acquiring corporation. In determining the tax consequences to the liquidating target, the reorganization provisions govern-not the liquidation rules of §§ 336 and…

“D” REORGANIZATION

“D” Reorganization

“D” reorganization: “Spin-off” and “Split-off”   acquisitive d reorganization “D” Reorganization Explanation: * Corporate T contains the assets of former corporation A and of T. * Corporation A goes out of existence Corporation A’s shareholder’s control Corporation T. Requirements for Divisive “D” d reorganization requirements imposed by IRC §355 * Distribution of Control -by the…